r 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Roomw12'-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

October 2, 2015 

File: J905 

FAA Project Number: 

ST07970NY-T 

References: 1. FAA Exemption No. 10422 (Docket No. FAA-2011-1052) 

Subject: Petition for Exemption Amendment- Company Name Change 

To whom it may concern, 

Please accept this letter as our petition to amend FAA Exemption Number 10422 (attached) 

to change the company name from ACS-NAI Ltd. to B/E Aerospace Limited. The company 

location remains unchanged from 25 Dunlop Avenue, Winnipeg, Manitoba Canada, R2X 

2V2. 

B/E Aerospace Limited was formerly known as ACS-NAI Ltd. Between the time period when 

Reference 1 was issued (December 2011) and today, our company name has changed as 

follows: 

• October 2013 -company name changed from "ACS-NAI Ltd." to "EMTEQ Canada 

Limited" 

• February 2014- Transport Canada Design Approval Organization Certificate DAO 

#98-C-01 re-issued in EMTEQ Canada Limited name 

• December 2014- company name changed from "EMTEQ Canada Limited" to "B/E 

Aerospace Limited" 

• February 2015- Transport Canada Design Approval Organization Certificate DAO 

#98-C-01 re-issued in B/E Aerospace Limited name 

This request is in support of current (and future) FAA validations of TCCA STCs held by B/E 

Aerospace Limited which include an Exemption from 25.813(e) as part of the Basis of 

Certification for the design change. 

Should you have any questions, please do not hesitate to contact me. 

Regards, 

4L 

Adam Coolidge, P. Eng. 

Certification Manager 

B/E Aerospace Limited 

Encl. 

25 Dunlop Avenue, Winnipeg, MB R2X 2V2 Canada • Office +1-204-783-5402 Fax +1-204-783-5436 • beaerospace.com 
Exemption No. 10422 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

ACS-NAI Ltd. 

for an exemption from§ 25.813(e) ofTitle 14, 

Code of Federal Regulations 

Regulatory Docket No. FAA-2011-1052 

GRANT OF EXEMPTION 

By letter dated September 13,2011, Mr. Ian Stewart, of ACS-NAI Ltd., 25 Dunlop Avenue, 

Winnipeg, MB, Canada R2X 2V2, petitioned for exemption from the requirements of 

§ 25.813(e) of Title 14, Code ofFederal Regulations (14 CFR). The petitioner has requested the 

exemption to permit installation of interior doors between passenger compartments on a 

Bombardier Aerospace Model CL-600-2B 19 airplane, to be designated as private use, not for 

hire, not for common carriage. 

The petitioner requests relief from the following regulation: 

Section 25.813(e), Amendment 25-461 - No door may be installed in any partition 

between passenger compartments. 

The petitioner supports their request with the following information: 

This section quotes the relevant information, with some edits for clarity, from the petitioner's 

request. Their complete petition is available at the Department of Transportation's Federal 

Docket Management System, on the Internet at http://regulations.gov, in Docket No. FAA-2011-

1052. 

1 For 14 CFR part 135 operations, there shall be instructions within the Airplane Flight Manual Supplement (AFMS) 

and Instructions for Continued Airworthiness (ICA) to provide a procedure to lock the door in the open position and 

install a cover plate to obscure the door and preventing the use of the door during flight. 
ACS-NAI Ltd. requests an exemption to Federal Aviation Regulations (FAR) 25.813(e) 

to permit the installation of doors in partitions between passenger compartments in CL600-2819 aircraft used for corporate transport. In support of this request, ACS-NAI Ltd. 

is attaching a copy ofTCCA Exemption NCRIRCN #147-2008 granting an exemption 

from the requirements of25.813(e). 

The CL-600-2B19 aircraft is designed to the requirements of FAR part 25, for Transport 

Category Aircraft. These rules are addressed to Transport Category airplanes that are 

used for the carriage of fare paying passengers from the general public and consider 

aircraft with passenger seating configurations of several hundred. The CL-600-2B 19 

aircraft configured with a corporate interior is Type Certified for a maximum of 19 

passengers. FAR part 25 does not provide segregation for intended use of the aircraft, 

such as commercial air transport or corporate use. 

The mid-cabin door installed for corporate interior configurations provides an increased 

level of comfort and privacy for the "office in the sky" concept. ACS-NAI Ltd. contends 

that aircraft interiors specifically designed for corporate operations should be eligible for 

an exemption [from] FAR part 25 requirements provided a level of safety is provided and 

can be demonstrated. 

Design Safety Features: 

1. The cabin of the CL-600-2B 19 is approximately 8-feet wide. In order to provide a 

private area for use as an office or bedroom, it is necessary to divide the cabin 

width laterally. A side corridor is not practical for the interior arrangement on CL600-28 19 aircraft. The doors to be installed will be sliding pocket doors with 

retracting footers. The sliding pocket door will be frangible to ensure it can be 

broken open during an emergency landing condition and to have blow-out 

capabilities to provide adequate decompression capabilities. 

2. The proposed doors will have a placard installed on both sides requiring the door 

to be secured within the bulkhead (i.e. door open) for taxi, take-off and landing. 

3. The proposed doors will be equipped with dual means to latch the door within the 

bulkhead to minimize the probability of the door deploying into the egress path 

during an emergency landing condition. Either means will be capable of 

supporting the inertia loads specified in FAR 25.561. 

4. A lighted annunciator will be installed in the cockpit instrument panel to alert the 

flight crew when the door is closed (i.e. across the egress path) and the airplane 

gear is down and locked, or flaps are not zero degrees. Due to the design 

philosophy of the cockpit and the configuration of the EICAS software for the 

CL-600-2B 19, posting a "cabin door" message on the EICAS is not possible. The 

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TCCA Exemption pem1its this signal as the annunciator is "effected in an 

equivalent manner" to posting on the EICAS. 

5. A description of the doors, passenger briefing requirements, limitations and 

procedures will be contained in the applicable Airplane Flight Manual 

Supplement and/or Flight Crew Operating Manual Supplement. 

Effect of the Exemption: 

The effect of the exemption considering the design safety features will ensure that there is 

a clear path through a cabin partition to an emergency exit. Should the cabin door be fully 

or partially closed following an emergency landing, there will still be simple means to get 

through the door to reach an exit. The frangibility feature will be tested using a 51h 

percentile female and the resulting opening will be demonstrated to be large enough for a 

951h percentile male to escape. These safety features would provide a level of safety for 

the passengers in a CL-600-2B 19 aircraft equal to that required for airline aircraft and 

other corporate aircraft such as the BD-700-1 A 1 0 and BD-700-1 A 11. 

Issue of Public Interest: 

Cabin doors have been installed in corporate aircraft such as the BD-700-lAIO and 

BD-700-lA 11. Interior cabin doors are commonly installed on corporate aircraft at the 

request of the members of the public that use these aircraft. The installation ofthese cabin 

doors [has] been shown to be adequately safe for corporate aircraft operations. 

It is our position that the above stated design safety features, the effect of the exemption 

and the issue of public interest provide an acceptable level of safety for passengers in a 

CL-600-2B 19 with an interior cabin door installed. Compliance has been established 

against TCCA Exemption NCR/RCN #147-2008 for the installation of an interior cabin 

door. 

We request to forgo the period for public consultation for the mid-cabin door exemption 

petition due to similarity with other FAA Exemption[s] [issued allowing] the installation 

of an interior cabin door. 

Federal Register publication 

The FAA has determined that good cause exists for waiving the requirement for Federal Register 

publication and comment because the exemption, if granted, would not set a precedent and any 

delay in acting on this petition would be detrimental to ACS-NAI Ltd. 

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The FAA's analysis 

The FAA considers the petitioner's proposal to be in the public interest for the same reasons as 

those previously stated by the petitioner. 

As more transport-category airplanes have been configured (or re-configured) for private use, the 

FAA has given considerable attention to the issue of appropriate regulation of such airplanes. 

Some of the current regulations governing design certification of transport-category airplanes are 

not compatible with private use of such airplanes. Because of this, we have received a number of 

petitions for exemption from certain regulations. We have granted such exemptions when we 

find that to do so is in the public interest and does not adversely affect the level of safety 

provided by the regulations. The FAA published Special Requirements for Private Use 

Transport Category Airplanes, SF AR No. I 09 (74 FR 21533, May 8, 2009), which significantly 

reduced the need for case-by-case review of individual petitions for exemption for private-use 

airplanes. This airplane can not use SFAR No. 109 because this is a new type-certificate project, 

and the SF AR is applicable to amended type-certificate and supplemental type-certificate 

programs only. 

The placement of interior doors is clearly quite significant to the owner/operator of the airplane. 

The flexibility to partition the airplane into individual rooms, such as private meeting rooms or 

bedrooms, is paramount to an acceptable interior. The availability of private meeting rooms and 

bedrooms is essential. The FAA acknowledges the desirability of these features from the 

operator's point of view. 

When the regulations pertaining to interior doors were adopted, they did not necessarily consider 

"rooms." They considered two possible types of interior doors in a passenger compartment. The 

first type is an interior door between passenger compartments. The second type is an interior 

door between the exit and the passenger compartment. 

Until recently, only the first type of door was prohibited by 14 CFR 25.813(e). However, part 25, 

as amended by Amendment 25-116, prohibits interior doors between the exit and the passenger 

compartment. In addition, Amendment 121-306 prohibits these doors in airplanes manufactured 

after November 27, 2006, operated under 14 CFR part 121. Amendments 25-116 and 121-306, 

titled Miscellaneous Cabin Safety Changes, were published in the Federal Register on 

October 27, 2004. 

Airplanes configured for private-use, not-for-hire, not-for-common carriage typically use any of 

five different categories of door in the passenger cabins: 

Category 1- A door in a room and the room is less than the full width of the airplane. An aisle 

is outside the room. This type of room may be occupied during taxi, takeoff, and landing, and 

only the occupants of the room must use the door to reach an exit. 

Category 2 - A door in a room and that is the same as Category 1, except a single emergency 

exit or pair of emergency exits is within the room. · 

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Category 3 - A door or doors in a compartment and the compartment is the full width of the 

airplane. Passengers are seated on both sides (fore and aft) of the door(s), and the main aisle 

leads out of, or passes through, the compartment. The compartment does not have emergency 

exits. This type of compartment may be occupied during taxi, takeoff, and landing with doors in 

the proper configuration. 

Category 4- A door in a room and the room is the full width of the airplane. Passengers are 

seated on both sides (fore and aft) ofthe door, and a pair of emergency exits is at one end of the 

room. This type of compartment may be occupied during taxi, takeoff, and landing with doors in 

the proper configuration. 

Category 5- A door in a room that may be the full width of the airplane. This type of room is 

not occupied during taxi, takeoff, and landing. This room is only occupied during flight. 

Passengers seated in taxi, takeoff, and landing seats must not need to pass through this door to 

get to any emergency exits. 

Because not all interior doors between passenger compartments are equivalent, the FAA has 

determined that the following requirements will produce an adequate level of safety: 

I. To maximize the level of safety, doors in Category 2, 3, or 4 installed across the main 

cabin aisle must open and close in a transverse direction. That is, the direction of motion 

of the door must be at a right angle to the longitudinal axis of the airplane. A "pocket 

door" is one example of such a design. This will tend to minimize the chance that the 

inertia forces of an accident could force the door closed. 

2. Redundant means are necessary to latch doors open for taxi, takeoff, and landing. Each 

latching means must have the capability of retaining the door in the taxi, takeoff, and 

landing position under the inertia forces of§ 25.561. 

3. Each interior door must be frangible, in the event that it is jammed in the closed position 

in flight or during taxi, takeoff, or landing. Frangibility is intended to ensure that if a door 

is jammed closed, occupants can escape in either direction and emergency equipment can 

be moved. Frangibility may be demonstrated in either ofthe fo11owing ways: 

• A 51h percentile female can break through the door, creating a large enough 

opening that a 95th percentile (or larger) male can pass through. (See Advisory 

Circular 25-17 A, Transport Ailplane Cabin Interiors Craslnvorthiness Handbook, 

paragraph 43b(2)). 

• A 5th percentile female can break a hinge on the door or a hinge on a smaller door 

within the door such that the door can swing open, allowing a 95th percentile (or 

larger) male to pass through the opening with the door swung open. This 

evaluation must be made with any cabin furnishing or equipment installed that 

could limit the swing-arc of the door with furnishing or equipment placed in the 

most adverse position. In using this approach, one must consider the possibility 

5 
that the door is physically jammed in the closed position by distortion of the 

fuselage or furnishings. This possibility must be considered even if the door 

normally translates into the open and closed positions. 

4. Doors that fall into Category 1 must be in the open position during taxi, takeoff, and 

landing only when the room is occupied. 

5. Doors that fall into Categories 2, 3, or 4 must be in the open position during taxi, takeoff, 

and landing, regardless of occupancy. 

6. Doors that fall into Category 5 must be in the closed position during taxi, takeoff, and 

landing. 

With respect to the possibility that a door remains closed when it should not be, we have 

determined that a higher level of awareness is required to address this issue. The petitioner's 

proposal to provide indication to the flight crew is considered adequate. 

After considerable deliberation, we conclude that installation of interior doors, with certain 

limitations, can be accepted. To maximize the level of safety, we require that certain limitations, 

including some proposed by the petitioner, be made mandatory to pem1it such installations. As 

noted previously, precedents have been set for this decision and which apply to other private-use, 

not-for-hire, not-for-common-carriage airplanes. 

The FAA's decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest and 

will not adversely affect the level of safety provided by the regulations. Therefore, pursuant to 

the authority contained in 49 U.S.C. 40113 and 44701, delegated to me by the Administrator, I 

grant the petition of ACS-NAI Ltd. for an exemption from the requirements of 14 CFR 25.813(e) 

to allow insta11ation of interior doors between passenger compartments on a Bombardier 

Aerospace Model CL-600-2819 airplane. This exemption is subject to the following conditions. 

Conditions 1, 3, 4, 5, and 6 must be documented as operating limitations in the Limitations 

section of the Airplane Flight Manual (AFM). Refer to Categories 1 - 5, listed earlier in this 

document, where conditions reference categories. 

This exemption is subject to the following conditions, and limitation numbers 1, 2, 3, 4, 5, and 6 

must be documented in the Limitations Section of the AFM: 

I. The airplane must not be operated for hire or offered for common carriage. This 

provision does not preclude the operator from receiving remuneration to the extent 

consistent with 14 CFR parts 125 and 91, subpart F, as applicable. 

2. Each door between passenger compartments must be frangible from both sides. A placard 

describing the frangibility procedure must be installed in a conspicuous location on both 

sides ofthe door. 

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• . ' II 

3. Doors that fall into Category I must be latched in the open position during taxi, takeoff, 

and landing when the room is occupied. A placard requiring the door to be in the open 

position must be installed in a conspicuous position on both sides of the door. 

4. Doors that fall into Categories 2, 3, or 4 must be latched in the open position during taxi, 

takeoff, and landing, regardless of occupancy of the room. A placard requiring the door 

to be in the open position must be installed in a conspicuous position on both sides of the 

door. 

5. Doors that fall into Category 5 must be in the closed position during taxi, takeoff, and 

landing. A placard requiring the door to be in the closed position, and requiring the room 

to be vacant, must be installed in a conspicuous position on both sides of the door. 

6. Appropriate procedures must be established to both signal the flightcrew in the event a 

door between passenger compartments is not in the proper position, and prohibit taxi, 

takeoff, or landing. Doors in Category 5 do not need to comply with this requirement. For 

Category 5 doors, placards located on or near the door, indicating that the door must be 

closed and the room must be vacant for taxi, takeoff, and landing, are acceptable. 

7. Doors between passenger compartments must have dual means to retain them in the open 

position. Each means must be capable of withstanding the inertia loads specified in 

§ 25.561. Doors in Category 5 do not need to comply with this requirement because they 

are required to be closed for taxi, takeoff, and landing. 

Issued in Renton Washington, on DEC 2 7 lOU 

~KC l \tu(l~ur\-tk \0-

K. C. Yartlmura 

Acting Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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